The Resource Constitutionality of the fixed and limited deduction of withholding taxes paid on U.S. dividends

Constitutionality of the fixed and limited deduction of withholding taxes paid on U.S. dividends

Label
Constitutionality of the fixed and limited deduction of withholding taxes paid on U.S. dividends
Title
Constitutionality of the fixed and limited deduction of withholding taxes paid on U.S. dividends
Subject
Summary
In the decision, the Tax Commission of First Instance of Rome suspended judgment regarding the application of Art. 15(1)(b) of the Italy-USA tax convention of 1955 and referred the case to the Constitutional Court. The Constitutional Court must decided whether Art. 15(1)(b) of the 1955 treaty is unconstitutional insofar as it provides solely for a fixed and limited deduction of the withholding taxes paid on U.S.-source dividends and insofar as it provides neither for a foreign tax credit nor for an imputation tax credit as Law 904 of 1977 does for dividends of Italian source
Citation source
In: European taxation. - Amsterdam. - Vol. 26 (1986),
Language note
English
http://library.link/vocab/subjectName
  • case law
  • dividend
  • tax treaty
Label
Constitutionality of the fixed and limited deduction of withholding taxes paid on U.S. dividends
Instantiates
Publication
Label
Constitutionality of the fixed and limited deduction of withholding taxes paid on U.S. dividends
Publication

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